Messaging Service Policies
Last Updated: October 1, 2022
These Messaging Service Policies (“Policies”) are intended to provide general guidance and policies regarding your use of the Messaging Services. We make no warranties in these Policies. These Policies are not inclusive or exhaustive and are subject to change at our discretion, at any time. We reserve the right in our sole discretion to remove or deny any traffic which does not comply with these Policies.
These Policies are hereby incorporated into the Agreement, its attachments, and all other documentation by reference. All capitalized terms that are used but not defined in these Policies shall have the respective meanings given to them in the Agreement, its attachments, and all other documentation, as well as rules and orders of the Federal Communications Commission as appropriate.
Our messaging solution supports superior quality and high integrity communications. These Policies are designed to promote best practices for exchange of messages. The viability of the messaging ecosystem is dependent on consumer perception of messaging as a trusted and convenient communication environment. These Policies are intended to preserve the credibility and utility of the ecosystem. These Policies are designed to enable wanted messages and prevent unwanted or deceptive messages. Those who violate these Policies may be subject to any penalty set forth below and, if applicable, those available to us under applicable law.
2. Enforcement and Violations
These Policies will be enforced by us and our upstream providers. Violations of these Policies may result in affirmative action taken by us and/or our upstream carriers.
- "Blacklisting” Numbers which have sent repeated known spam/unwanted content are subject to automatic blacklisting without notification for up to 30 days. Multiple or repeat offenses may result in permanent blacklisting. Additionally, numbers which have been reported by industry partners for spam/unwanted content may also be subject to permanent blacklisting.
- “Consumer” means an individual person with uniquely assigned phone numbers (long codes i.e., local phone numbers) who subscribes to specific wireless messaging services or messaging applications. Consumers do not include agents of businesses, organizations or entities which send messages to consumers.
- “Non-Consumer” means a business, organization or entity which uses messaging to communicate with consumers. Examples may include, but are not limited to, large-to-small businesses, financial institutions, schools, medical practices, customer service entities, non-profit organizations and political campaigns.
- “Non-Consumer Application-to-Person (A2P)” means messages sent from an application, typically web-based, to a mobile subscriber. Some common use cases include two-factor authentication (“2FA”), travel notifications, banking alerts or marketing messages. A2P delivery methods are either via toll-free messaging service or soon to be implemented 10-digit long code (“10DLC”).
- “Fingerprinting” means the process of extracting data points from identified spam content is known as “fingerprinting”. Once message content has been fingerprinted as spam, all content found to be correlated to that fingerprint will be blocked in the future. Fingerprints do not expire or age out of existence.
- “MM4” is a 3GPP protocol for MMS service which covers the routing of an MMS from an originator MMS relay/server to a recipient MMS relay/server. MM4 is based on SMTP (email) protocol. MM4 is an extension of Internet simple mail transport protocol (SMTP) according to STD 10 (RFC 2821).
- “Multimedia Message Service” or “MMS” facilitates group messaging and allows for the exchange of multimedia content between mobile devices including video, pictures and audio.
- “REST API” means the application programming interface (“API”) used to establish messaging connectivity for sending and receiving messages and other service-related access.
- “Short Message Service” or “SMS” (commonly known as “text messaging”) means a service for sending and receiving messages of up to 160 characters to mobile devices. Longer messages will be fragmented into smaller message fragments. Maximum character length per message fragment varies depending on the character set used in the body of the message, whether GSM default alphabet or Unicode.
- “Short Message Peer-to-Peer” or “SMPP” means an open, industry standard Internet protocol designed to provide a flexible data communication interface for the transfer of SMS messages between external short messaging entities (“ESME”), routing entities (“RE”) and short message service centers (“SMSC”).
- “Unwanted Messages” include, but are not limited to, unsolicited bulk commercial messages (i.e., spam); “phishing” messages intended to access private or confidential information through deception; other forms of abusive, harmful, malicious, unlawful or otherwise inappropriate messages; and messages which require an opt-in but did not obtain such opt-in (or such opt-in was revoked).
4. Global Policiesa. General Rules of Content: Message senders should take affirmative steps and employ tools which monitor and prevent unwanted message content, including content which:
- is unlawful, harmful, abusive, malicious, misleading, harassing, violent, obscene/illicit, or defamatory;
- is deceptive (e.g., phishing messages intended to access private or confidential information), including deceptive links;
- invades privacy;
- causes safety concerns;
- incites harm, discrimination, hate or violence;
- is intended to intimidate;
- includes malware;
- threatens Consumers; and/or
- does not meet age-gating requirements.
b. Political Use Cases: Political messaging will be evaluated on a case-by-case basis. Such discretion will not be exercised with the intent of favor or disfavor of any political party or candidate. Due to high volumes of Consumer complaints, messages containing the following content are not appropriate and may be blocked by carriers if sent over either P2P or A2P (toll-free/10DLC) messaging, regardless of opt-in status:
- spoofing messages or snowshoed content across multiple numbers
- data sharing between message senders
- malicious content
- phishing content
c. Inappropriate Use Cases: Due to high volumes of Consumer complaints, messages containing the following content are not appropriate and may be blocked by carriers if sent over A2P (toll-free/10DLC) messaging, regardless of opt-in status. If messaging traffic is identified by a provider as associated with one of the following use cases, we are not responsible for and cannot assist in the removal of blocking. Such use cases include:
- social marketing
- financial services, whether account notifications, marketing, collections or billing for high-risk/subprime lending/credit card companies, auto loans, mortgages, payday loans, short-term loans, student loans, debt consolidation/reduction/forgiveness
- insurance, including car and health insurance
- gambling, casino, and bingo
- gift cards
- free prizes
- investment opportunities
- lead generation
- commission programs
- credit repair
- tax relief
- illicit or illegal substances (including cannabis)
- work from home
- get rich quick
- UGGS and RayBan campaigns
- fraud or scams
- deceptive marketing
- SHAFT: Sex, Hate, Alcohol, Firearms or Tobacco
d. Additional Prohibited Practices
- Snowshoe Messaging: Snowshoe sending is a technique used to send messages from more source phone numbers or short codes than are needed to support an application’s function. This technique is often used to dilute reputation metrics and evade filters. Message senders must not engage in snowshoe messaging. You should also take measures to prevent snowshoe messaging. Certain cases with similar campaigns may use different numbers. In that case, it is important for message senders to identify their messages with a distinct brand and URL naming convention. If there is any doubt about campaign content, submit use case proposals or questions to email@example.com.
- Proxy Numbers: Message senders might utilize a phone number as a proxy number, which functions as a relay point between possibly large sets of phone numbers and/or frequently changing phone numbers in certain wireless messaging use cases. For example, a driver for a ride-sharing service may need to communicate with a prospective passenger to confirm a pick-up location. The proxy phone number functions as a conference call bridge phone number, allowing the driver and passenger to communicate without either party having to reveal their personal phone number. A 10-digit NANP phone number used as a proxy is typically a means to connect two individuals, but proxy numbers are commonly reused in a way which may create volumes of messaging traffic exceeding typical Consumer operation. Given the use of proxy numbers to facilitate bulk messaging traffic among multiple 10-digit NANP phone numbers, the proxy number qualifies as Non-Consumer A2P messaging traffic and may be subject to additional validation, vetting and monitoring.
- Spoofing Phone Numbers: Message number spoofing includes the ability of a message sender to cause a message to display an originating number for the message, which is not assigned to the message sender, or when a message sender originates a message through a service provider other than the service provider to which reply messages will be delivered or received. Message number spoofing must be avoided and must comply with all applicable laws.
5. Non-Consumer A2P Best Practicesa. Consumer Consent: The messaging ecosystem must operate consistent with relevant laws and regulations, such as the TCPA and associated FCC regulations regarding Consumer consent for communications. Regardless of whether these rules apply to and maintain Consumer confidence in messaging services, Non-Consumer A2P message senders should:
- obtain a Consumer’s consent to receive messages;
- obtain a Consumer’s express written consent to specifically receive marketing messages; and
- ensure Consumers have the ability to revoke consent.
Consent may vary upon the type of message content exchanged with a Consumer.
The table below provides examples of the types of messaging content and the associated consent that should be expected. The examples below do not constitute or convey legal advice and should not be used as a substitute for obtaining legal advice from qualified counsel. Reference to “business” below is used as an example of a Non-Consumer A2P message sender. Individual service providers may adopt additional Consumer protection measures for Non-Consumer A2P message senders, which may include, for example, campaign pre-approval, service provider vetting, in-market audits, or unwanted message filtering practices which are tailored to facilitate the exchange of wanted messaging traffic.
Types of Messaging Content & Associated Consent Principles
Conversational messaging is a back-and-forth conversation which takes place via text. If a Consumer texts a business first and the business responds quickly with a single message, then it is likely conversational. If the Consumer initiates the conversation and the business simply responds, then no additional permission is expected.
Informational messaging is when a Consumer gives their phone number to a business and asks to be contacted in the future. Appointment reminders, welcome texts, and alerts fall into this category because the first text sent by the business fulfills the Consumer’s request. A Consumer needs to agree to receive texts for a specific informational purpose when they give the business their mobile number.
Promotional messaging is a message sent which contains a sales or marketing promotion. Adding a call-to- action (e.g., a coupon code to an informational text) may place the message in the promotional category.
Before a business sends promotional messages, the Consumer should agree in writing to receive promotional texts.
Businesses which already ask Consumers to sign forms or submit contact information can add a field to capture the Consumer’s consent.
First message is only sent by a Consumer
First message is sent by the Consumer or business
One-way alert or two-way conversation
First message is sent by the business
Message responds to a specific request
Message contains information
Message promotes a brand, product, or service
Prompts Consumer to buy something, go somewhere, or otherwise take action
If the Consumer initiates the text message exchange and the business only responds to each Consumer with relevant information, then no verbal or written permission is expected.
The Consumer should give express permission before a business sends them a text message. Consumers may give permission over text, on a form, on a website or verbally. Consumers may also give written permission.
EXPRESS WRITTEN CONSENT
The Consumer should give express written permission before a business sends them a text message.
Consumers may sign a form, check a box online, or otherwise provide consent to receive promotional text messages.
b. Clear and Conspicuous Calls-to-Action: A “call-to-action” is an invitation to a Consumer to opt-in to a messaging campaign. The primary purpose of disclosures is to ensure that a Consumer consents to receive a message and understands the nature of the program. Message senders must display a clear and conspicuous call-to-action with appropriate disclosures to Consumers about the type and purpose of the messaging Consumers will receive. A call-to-action must ensure Consumers are aware of:
the program or product description;
the phone number(s) or short code(s) from which messaging will originate;
the specific identity of the organization or individual being represented in the initial message;
clear and conspicuous language about opt-in and any associated fees or charges; and
Calls-to-action and subsequent messaging must not contain any deceptive language, and opt-in details must not be obscured in terms and conditions (especially terms related to other services).
c. Consumer Opt-In: Message senders should support opt-in mechanisms, and messages should be sent only after the Consumer has opted-in to receive them. Opt-in procedures reduce the likelihood that a Consumer will receive an unwanted message. It can also help prevent messages from being sent to a phone number which does not belong to the Consumer who provided the phone number (e.g., a Consumer purposefully or mistakenly provides an incorrect phone number to the message sender).
Depending upon the circumstances, a Consumer might demonstrate opt-in consent to receive messaging traffic through several mechanisms, including but not limited to:
- entering a phone number through a website;
- clicking a button on a mobile webpage;
- sending a message from the Consumer’s mobile device that contains an advertising keyword;
- initiating the text message exchange in which the message sender replies to the Consumer only with responsive information;
- signing up at a point-of-sale (POS) or other message sender on-site location; or
- opting-in over the phone using interactive voice response (IVR) technology.
While the common short code handbook is a separate document specific to the common short code program, the common short code handbook has additional examples of opt-in consent which may be helpful to message senders. Message senders should also document opt-in consent by retaining the following data where applicable:
- timestamp of consent acquisition;
- consent acquisition medium (e.g., cell-submit form, physical sign-up form, SMS keyword, etc.);
- capture of experience (e.g., language and action) used to secure consent;
- specific campaign for which the opt-in was provided;
- IP address used to grant consent;
- Consumer phone number for which consent to receive messaging was granted; and
- identity of the individual who consented (name of the individual or other identifier (e.g., online username, session ID, etc.)).
- the program name or product description;
- customer care contact information (e.g., a toll-free number, 10-digit phone number, or help command instructions);
- how to opt-out;
- a disclosure that the messages are recurring and the frequency of the messaging; and
- clear and conspicuous language about any associated fees or charges and how those charges will be billed.
e. Consumer Re-Opt-In on Toll-Free Numbers: A Consumer may opt-in to a toll-free A2P campaign by texting the word “UNSTOP” to the sender’s toll- free number. This keyword is not case sensitive and triggers opt-in only when sent as a single word. Examples of valid re-opt-ins include UNSTOP and variations such as unstop, Unstop or UNStop.
f. Single Opt-In per Campaign: Opt-ins are not transferable. A Consumer opt-in to receive messages should not be transferable or assignable. A Consumer opt-in should apply only to the campaign(s) and specific message sender for which it was intended or obtained.
g. Renting, Selling, or Sharing Opt-In Lists: Message senders should not use opt-in lists which have been rented, sold or shared to send messages. Message senders should create and vet their own opt-in lists.
h. Consumer Opt-Out: Opt-out mechanisms facilitate Consumer choice to terminate messaging communications, regardless of whether Consumers have consented to receive the message. Message senders should acknowledge and respect Consumers’ opt-out requests consistent with the following:
- message senders should ensure Consumers have the ability to opt-out of receiving messages at any time;
- message senders should support multiple mechanisms of opt-out, including phone call, email or text;
- message senders should acknowledge and honor all Consumer opt-out requests by sending one final opt-out confirmation message per campaign to notify the Consumer that they have opted- out successfully. No further messages should be sent following the confirmation message; and
- message senders should state in the message how and what words effect an opt-out. Standardized “STOP” wording should be used for opt-out instructions, however opt-out requests with normal language should also be read and acted upon by a message sender except where a specific word can result in unintentional opt-out. The validity of a Consumer opt-out should not be impacted by any de minimis variances in the Consumer opt-out response, such as capitalization, punctuation or any letter-case sensitivities.
Examples of valid opt-out messages include: STOP, Quit, Cancel, Unsubscribe, End, and Opt Me Out (including variations of these words such as Stop or STop)
i. High Opt-Out Rate: Message senders who receive high volumes of opt-outs could be flagged for poor sending practices. Where the daily opt-out rate is 5% or higher, the toll-free carrier or other carriers may monitor the campaign. The carrier may reach out for campaign and opt-in details and/or suspend services of high opt-out rate flagged campaigns at its discretion, not to be unreasonably exercised. “Daily opt-out rate” is the total number of subscribers who received a campaign’s SMS divided by the number of opted out subscribers who received a campaign’s SMS in a 24-hour period.
j. Maintaining and Updating Consumer Information: Message senders should retain and maintain all opt-in and opt-out requests in their records to ensure future messages are not attempted (in the case of an opt-out request) and Consumer consent is honored to minimize Unwanted Messages. Message senders should process phone deactivation files regularly (e.g., daily) and remove any deactivated phone numbers from any opt-in lists.
k. Privacy and Security: Message senders must address both privacy and security comprehensively in the design and operation of messaging campaigns. We are not responsible or liable for any security or breaches experienced by the message sender.
- Implement Reasonable Physical, Administrative, and Technical Security Controls to Protect and Secure Consumer Information: Message senders should implement reasonable security measures for messaging campaigns that include technical, physical, and administrative safeguards. Such safeguards should protect Consumer information from unauthorized access, use, and disclosure. Message senders should conduct regular testing and monitoring to ensure such controls are functioning as intended.
- Conduct Regular Security Audits: Message senders should conduct either a comprehensive self-assessment or third-party risk assessment of privacy and security procedures for messaging campaigns on a regular basis and take appropriate action to address any reasonably foreseeable vulnerabilities or risks.
- Prevention of Unlawful Activities or Deceptive, Fraudulent, Unwanted or Illicit Content: Message senders should use reasonable efforts to prevent and combat unwanted or unlawful messaging traffic, including spam and unlawful spoofing. Specifically, message senders should take affirmative steps and employ tools to monitor and prevent Unwanted Messages and content, including for example content that: (1) is unlawful, harmful, abusive, malicious, misleading, harassing, excessively violent, obscene/illicit, or defamatory; (2) deceives or intends to deceive (e.g., phishing messages intended to access private or confidential information); (3) invades privacy; (4) causes safety concerns; (5) incites harm, discrimination, or violence; (6) is intended to intimidate; (7) includes malware; (8) threatens Consumers; or (9) does not meet age-gating requirements. Message senders can also review the common short code handbook for further examples of unwanted message content. Further, message senders should take steps to ensure marketing content is not misleading and complies with the Federal Trade Commission’s (FTC) Truth-In-Advertising rules.
- Embedded Website Links: Message senders should ensure links to websites embedded within a message do not conceal or obscure the message sender’s identity and are not intended to cause harm or deceive Consumers. Where a web address (i.e., Uniform Resource Locator (URL)) shortener is used, message senders should use a shortener with a web address and IP address(es) dedicated to the exclusive use of the message sender. Web addresses contained in messages as well as any websites to which they redirect should unambiguously identify the website owner (i.e., a person or legally registered business entity) and include contact information, such as a postal mailing address.
- Embedded Phone Numbers: Messages should not contain phone numbers that are assigned to or forward to unpublished phone numbers, unless the owner (i.e., a person or legally registered business entity) of such phone numbers is unambiguously indicated in the text message.
- Toll-Free Campaign Registration: For high volume and important toll-free campaigns, we recommend registration with the toll-free provider before sending traffic. The information below is required for campaign review. The review time is generally 4–5 business days. Submit all use case information to https://form.jotform.com/213426151593150.
- Use Case Information
- 8XX toll-free Number
- Use Case Summary
- Opt-In Process
- Message Examples
- Terms URL
n. Political Messaging: Political campaigns should abide by the M3AAWG Mobile Messaging Best Practices for Political Programs Best Practices.
- T-Mobile Political Messaging: To run 10DLC messaging campaigns on the T-Mobile network, a special registration and third-party verification check is required (Campaign Verify). This is required to ensure the authenticity of the political entity. Political candidates are required to send extended information that includes the following requirements:
- Campaign must be on a dedicated application address
- 10DLC only: Vetting must be confirmed through Campaign Verify (www.campaignverify.org)
- Campaign Verify Token
- FEC Committee ID
- Politician/Organization Name
- Politician/Organization Website
- Opt-Out: Opt-out must be below 1%
- Stop Language: Campaigns must send stop language on the 1st and 5th message or once a month for continued customer awareness. However, sending it on every message is recommended.
- Single Number Sending: If a single number gets blocked with the Canadian carriers, do not move traffic to another number.
- Brand Identity: Messages should always identify the sender of the message.
- Message Frequency: The number of messages sent to a subscriber should not exceed 10 in a month. If there is an expectation that the subscriber will receive multiple messages, state so during the opt-in process.
- Customer Support Keywords: Campaigns should support HELP, INFO and STOP as well as all French translations and send a bounce back in the corresponding language of the keyword.
- False Positives: We monitor on behalf of customers, but we encourage any issues to be reported to firstname.lastname@example.org.
- Data Rates May Apply Verbiage: When a customer receives a message termination (MT) with a link to a website, messages must also state that “Data rates may apply.”
The following industry resources may be helpful as a message sender starts to craft messaging content. Messages should follow guidance from these resources, otherwise messages may be blocked.
- CTIA Messaging Principles and Best Practices
- FTC Truth in Advertising
- MMA Best Practices
- M3AAWG Best Practices
- M3AAWG Mobile Messaging Best Practices for Political Programs
- Telephone Consumer Protection Act (TCPA) Omnibus Declaratory Ruling (FCC 15-72)
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